What this means
Start with the exact decision in front of you.
A compliance enquiry may concern the operator, a Personal Management Licence holder or both. Identify whether the Commission is requesting information, investigating an offence or considering a licence review before responding.
Immediate priorities
Organise the position before responding.
Save the complete request and response timetable
Identify your management office and licence conditions
Coordinate with the operator without surrendering an independent account
Detailed guidance
The procedure, evidence and possible route from here.
01
Establish whose licence is in issue
A Gambling Commission enquiry may concern an operator's operating licence, an individual's Personal Management Licence or both. Read the request for the licence numbers, named recipients, suspected issue and power used. A PML holder should not assume that a corporate response answers their personal position. Equally, holding a senior title does not make the individual personally responsible for every operating-licence control without evidence of their role and decisions.
Record whether the contact is routine compliance, information gathering, an investigation or notice of a section 116 review. Those stages carry different representation and outcome possibilities. Identify the specified management office held, licence conditions and period concerned. PML requirements expanded in November 2024 for certain management roles, so verify which requirements applied at the relevant time rather than using an outdated organisational chart.
- Record each licence and legal recipient
- Identify the PML management office and relevant period
- Confirm whether a formal review has begun
02
Preserve an independent evidence trail
Secure governance minutes, risk assessments, policy versions, compliance monitoring, customer cases, AML records, key-event reports and communications relevant to the concern. Preserve original dates and authors. Create a role map showing what the PML holder controlled, what was delegated and what was escalated. If operator systems contain the evidence, agree lawful access early, especially where employment or board service may end.
The operator and individual may initially share objectives, but interests can diverge on knowledge, responsibility and sanction. Identify who represents each licensee and whether a joint interview or submission creates conflict. Do not allow a settlement by the operator to become an untested admission by the PML holder. The holder's response should still address adverse documents candidly and explain decisions from the information available at the time.
- Preserve source records and policy versions
- Map authority, delegation and escalation
- Review conflicts between operator and holder
03
Control the first response
Acknowledge the request, diary the deadline and answer the actual questions. If material is unavailable or the scope is unclear, explain why and propose a practical response plan. The Commission expects openness and cooperation, but that does not require speculation or an immediate admission. Separate facts personally known, facts shown by records and conclusions reached only after later documentary review.
Check whether the concern also triggers a personal key-event report, operator notification, employment disclosure or law-enforcement contact. Each has its own timing and recipient. Maintain a submission log so the same event is described consistently. The aim is accurate cooperation and early identification of risk, not predicting whether the Commission will close the enquiry, commence a review or impose interim suspension.
- Answer the request within its stated scope
- Separate personal knowledge from later reconstruction
- Map all notification deadlines
Key questions
Keep the analysis tied to this stage.
Scope of the Commission's concern
Personal duties connected to the management role
Whether the matter may progress to formal review
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Does a Commission enquiry mean my PML is under formal review?
Not always. Confirm whether the Commission has issued a section 116 review notice or is still gathering compliance information.
Can the operator answer for the PML holder?
The operator can provide corporate evidence, but a PML is personal. The holder should ensure any account of their role and decisions is accurate.
Connected guidance
Continue through the topic map.
Use the hub for the full sequence or choose the connected route that matches the notice.
Official sources
Check the material for this question.
Sources checked 19 September 2026. Rules change, so compare the current notice and linked official material and tell the operator if a citation or summary needs correction.